What if the former delivery-service provider misses the deregistration deadline?
Short answer
If the former certified delivery-service provider does not deregister the participant from the central Service Metadata Publisher, or SMP, within three working days after the contract ends, a complaint may be submitted to the Slovak Peppol Authority, a role performed by the Financial Directorate of the Slovak Republic.
Reference period
Basis for assessing whether it is a delay.
On the Peppol authority of the Slovak Republic
It is submitted to the Financial Directorate of the Slovak Republic as a supervisory authority.
Blocked registration with a new provider
The uniqueness of the identifier prevents simultaneous registration with two providers.
Enforcing deregistration
The initiative should lead to correction by the original provider.
Detailed explanation
Whilst the deadline is running, the entity remains technically assigned to the original provider and the new provider cannot register it in their register, as the subscriber identifier is unique within the Peppol network. Submitting a complaint to the Peppol Authority is therefore a practical step if a company or its new provider believes that the original provider is, either intentionally or through negligence, delaying the deregistration process beyond the specified deadline, thereby preventing the switch to the new provider.
As set out in the Act
Supervision of certified delivery service providers and their obligations is carried out by the Peppol Authority of the Slovak Republic, which is the Financial Directorate of the Slovak Republic, on the basis of powers delegated by the Peppol Co-ordinating Authority. The obligations of a certified provider arise from Section 76a of Act No. 222/2004 Coll. on VAT, as amended by Act No. 385/2025 Coll.
Practical examples
- The company discovers that, ten days after the termination of the contract, it has still not been deregistered with the original provider, and lodges a complaint with the Peppol Authority.
- The new provider informs the client that it cannot complete the registration until the original provider has cancelled its record.
- Following intervention by the Peppol authority, the original provider subsequently completes the deregistration.
Most common mistakes
- “If the deadline for deregistration is not met, there is no remedy available.” The company or the new provider may lodge a complaint with the Peppol Authority of the Slovak Republic.
- “A new provider may register an entity even though the original provider has not yet deregistered it.” The uniqueness of the identifier in the Peppol network does not allow for such concurrent registration.
- “Any issue raised with the Peppol authority is dealt with exclusively by the provider’s technical department.” This is a supervisory mechanism applied to providers by the Financial Directorate of the Slovak Republic in its capacity as the Peppol authority.
Conclusion
A missed three-working-day deregistration deadline may be reported to the Slovak Peppol Authority at the Financial Directorate.
Legal basis
- Act No. 222/2004 Coll. on VAT, Section 76a (as amended by Act No. 385/2025 Coll.)
- Competences of the Peppol Authority of the Slovak Republic (Financial Directorate of the Slovak Republic)
Related questions
- What is the timeframe for the original sender?
- Will there be an outage when the change takes place?
- What should you look out for in the terms and conditions?
This is not legal advice. Sources: Act No. 222/2004 Coll. on VAT, Act No. 431/2002 Coll. on Accounting, official methodological and information materials from the Slovak Financial Administration on e-invoicing, the Peppol (OpenPeppol) network operating rules and the Peppol Authority Specific Requirements for the Slovak Republic. Verified on 7 July 2026.